LIHEAP Dear Colleague Letter Revisions to the Proposed New LIHEAP Performance Measures
- Low Income Home Energy Assistance Program (LIHEAP)
- Guidance, Policies, Procedures, Dear Colleague Notices
LOW-INCOME HOME ENERGY
Dear Colleague Letter
U.S. Department of Health and Human Services
Administration for Children and Families
Office of Community Services
Division of Energy Assistance
370 L'Enfant Promenade, S.W.
Washington, D.C. 20447
Date: December 17, 2013
TO: LOW INCOME HOME ENERGY ASSISTANCE PROGRAM (LIHEAP) GRANTEES
SUBJECT: Revisions to the Proposed New LIHEAP Performance Measures
As you know, the Office of Community Services (OCS) has been working collaboratively with our state grantees, particularly through state representation on the LIHEAP Performance Measures Implementation Work Group, for the past several years on the development and implementation of new performance measures. This year we initiated the clearance process to begin using several new measures. This letter provides notice of upcoming webinars that will discuss the status of these new measures. This letter also highlights some of the changes we are now proposing for the new measures in light of public comments we received this year.
We seek your participation on one of the following webinars that will discuss the proposed revisions to the LIHEAP performance measures that we are seeking clearance to require of state grantees in future years:
- December 19, 2013 at 3 pm EST
- January 14, 2013 at 2 pm EST
To join one of these webinars, please:
- Call 1-888-455-3614
- Enter passcode 8297655#
- Go to the following web URL: https://www.mymeetings.com/nc/join.php?i=PW3339590&p=8297655&t=c
Need for Performance Measures
The Office of Community Services is required by the LIHEAP statute to report to Congress on program impacts annually, to develop performance goals, to ensure that benefits are targeted to those households with the greatest home energy need, and to assure that timely resources are available to households experiencing home energy crises. More specifically:
- Section 2605(b) of the Low Income Home Energy Assistance Act of 1981 (42 U.S.C. §8624(b)) as amended by Sec. 311(b) of the Human Services Amendments of 1994 (Public Law 103-252) requires HHS to develop, in consultation with LIHEAP grantees, model performance goals that measure the success of each State’s LIHEAP activities.
- Section 2610(b)(2) of the Low Income Home Energy Assistance Act of 1981 (42 U.S.C. §8629(b)(2)) requires that HHS annually report to Congress on the impact LIHEAP is making on recipient and income eligible households (see Attachment 1 for statutory language).
- Section 2605(b)(5) of the Low Income Home Energy Assistance Act of 1981 (42 U.S. C. §8624(b)(5)) requires LIHEAP grantees to provide, in a timely manner, that the highest level of energy assistance will be furnished to those households that have the lowest incomes and the highest energy costs or needs in relation to income, taking into account family size.
- Section 2604(c) of the Low Income Home Energy Assistance Act of 1981 (42 U.S. C. §8623(c)) requires that grantees reserve a reasonable amount of LIHEAP funds (based on data from prior years) until March 15 of each program year for energy crisis intervention. Furthermore, grantees are required to address home energy crises within expedited timeframes.
Since 1994, OCS has worked with grantees to evaluate and develop performance measures for LIHEAP program impacts. Development of these proposed performance measures has taken several years, at the request and recommendation of LIHEAP grantees. Specifically, members of the LIHEAP Performance Measures Implementation Work Group (PMIWG), all representatives from State LIHEAP grantees, have led the design and development of these measures. They provided early testing of the feasibility of implementing such measures, training for fellow grantees on best practices in performance measurement and establishment of relationships with utility vendors, and have been advocates for the importance of performance measurement in LIHEAP.
Status of New Performance Measures
As a result of these efforts, OCS published a Federal Register notice on June 6, 2013, announcing our intent to seek authorization to require state LIHEAP grantees to report on several new outcome-based LIHEAP performance measures.
Concerns expressed in these comments can be summarized in three main categories:
- Relevance and Usefulness of Data: Questions about why the measures are relevant to assessment of program outcomes. Assertions that the program has operated effectively without these data.
- Estimated Burden: Concerns for burden on sub-grantees, grantees, small energy vendors, and large energy vendors. Specific concern that resources devoted to data collection and reporting would detract from level of benefits and timely service.
- Data Quality: Questions about whether good quality data could be collected for a mobile population that uses multiple energy sources and vendors.
In response to the issues and concerns raised by the comments to the first Federal Register Notice, OCS has made several adjustments to its proposed data collection, as discussed below.
Reformulation of Energy Burden Reduction Measure
As a response to comments regarding relevancy and data quality, the originally-proposed performance measure for energy burden reduction will be calculated as two indices. This includes both an Energy Burden Reduction Index and a Benefit Targeting Index. These indices represent more robust measures than the one previously proposed and will provide grantees and OCS with more meaningful data to use in program development and evaluation.
Previously Required Data Elements will be Optional
In an effort to address concerns about the burden of reporting, some previously required data elements are now being proposed as optional. Specifically, household utility consumption data and supplemental fuel and air conditioning expenditure and consumption data, originally required for the energy burden reduction measure, will be optional for all grantees. Grantees will be encouraged to collect this information wherever possible so that OCS can identify best practices, strategies, and benefits associated with this information.
Burden Reduction Sampling Plans to be Developed
OCS also is developing best practice information to demonstrate to grantees how to collect the highest quality data with the lowest burden. As part of that effort, OCS is working collaboratively with a State grantee that already collects the required data to develop an effective vendor and client sampling procedure that will furnish performance indicators within the targeted precision guidelines.
Renaming of Prevention and Restoration Measures to Eliminate Confusion
To avoid confusion and ensure quality and consistency of data, the term “crisis” was removed from the names of the energy loss prevention and restoration measures. It is important that all grantees have a common definition for these measures. Specifically, grantees will report on cases of energy loss prevention and restoration as a result of households receiving any type of LIHEAP funding. As the term “crisis” refers to a specific LIHEAP component, it was removed to minimize confusion in reporting.
Home Energy Expenditure Analysis
The data quality has also been confirmed with respect to relying on total residential energy expenditure data in order to infer home heating and cooling expenditures. Analysis has been conducted confirming a strong correlation between total residential energy expenditure and home energy burden, such that no statistical modeling is necessary to extrapolate to the home heating and cooling expenditure level.
Ongoing Technical Assistance
It is correct to be concerned that it is difficult to collect energy expenditure and burden information for some low-income households. OCS is committed to furnishing on-going technical assistance to grantees to help develop procedures for getting better information on clients and their home energy needs, and as a side benefit will improve the quality of benefit targeting and burden reduction targeting data.
OCS is now proposing to collect annual data that will establish four performance indicators of the impact of LIHEAP services on its recipients. The data collected will be synthesized to create the following performance measures:
- Benefit Targeting Index for High Burden Households – measures the extent to which the highest benefits are provided to the LIHEAP recipient households with the highest energy burden (the percent of gross income spent on utility costs);
- Energy Burden Reduction Index for High Burden Households – measures the extent to which LIHEAP benefits are adequate to deliver the same energy burden reduction to high burden recipient households as to low and moderate burden recipient households;
- Prevention of Loss of Home Energy Services - the unduplicated count of households where LIHEAP prevented the loss of home energy services; and
- Restoration of Home Energy Services - the unduplicated count of households where LIHEAP restored home energy services to the client.
Specific data elements OCS is seeking to collect for each of the four performance measures are detailed below.
Benefit Targeting Index and Energy Burden Reduction Index
For all bill-payment households, by main heating fuel and for all high energy burden households (top 25%), by main heating fuel
Prevention of Loss of Home Energy Services (unduplicated number of households)
Restoration of Home Energy Services
The proposed data collection form and instructions are attached.
After we conduct both webinars and incorporate any further revisions necessary, we will publish a second Federal Register notice that will seek 30 days of public comments to be sent to the Office of Management and Budget which is the office that provides clearance of federal data collection activities.
To further discuss the proposed revisions and next steps with this process, OCS strongly encourages all grantees and other stakeholders to attend one of the webinar dates. The webinars will cover the same information, so we encourage everyone to attend at least one of the dates. We encourage you to submit questions to our office in advance of the webinars so that we can address them during the webinars.
Please call or email your liaisons if you have any questions about the webinar. Please call or email Leon Litow if you have any questions that you would like addressed during the webinar. This information will also be posted to the LIHEAP web site under Dear Colleague Letters.
Jeannie L. Chaffin
Office of Community Services
Attachment (1) Performance Measures Form
Attachment (2) Performance Measures Form Instructions